Privacy Policy

  • Updated


Version: 2.2
Date updated: January 6, 2022

At VGW, we are committed to protecting and respecting your privacy and maintaining the confidence and  trust of our customers. This privacy policy (“Privacy Policy”) explains how your personal information is  collected, why it is collected and how it is kept secure. 

This Privacy Policy governs the manner in which VGW Holdings Limited, VGW Luckyland Inc (“Luckyland”),  and other companies in the VGW Group (“VGW Group”) collect, use, maintain and disclose information  collected from users (each, a "User") of Luckyland through and any  subdomains, subpages, successor sites or any application accessible via our Website (“Website”). This  Privacy Policy applies to the website and all products and services offered through the Website.



1.1. This Privacy Policy is issued on behalf of the VGW Group so when we mention “VGW”, "we", "us" or  "our" in this Privacy Policy, we are referring to the relevant company in the VGW Group responsible  for processing your data. 

1.2. The data controller responsible for processing data collected through your use of the Website  (including any data you may provide through the Website when you purchase a product or service or  take part in a promotion or competition) is VGW US Inc having its address at PO Box 20763, Boulder, CO 80308 (the “Data Controller”).



2.1. We collect two basic types of information - personal information (as defined below) and anonymous  information (as defined below) - and we may use personal and anonymous information to create a  third type of information, aggregate information (also defined below).

For example, we collect:

2.1.1. contact details, such as your first name and surname, email address,
residential address and mobile or other phone numbers;

2.1.2. personal information such as gender, age, age range or your image;
account login details,including your username, password and pictures
associated with your profile;

2.1.3. transaction information you provide when you make a purchase,
request a redemption or otherwise use our Website or contact customer
service, such as your postal address,  phone number and payment or
redemption information including banking and financial  details, credit
card details and bank account statements;

2.1.4. information sent bilaterally or within a small group using text
message, live chat, post or other similar methods of communication;
information we obtain from a third  party, such as a site or platform
(including Facebook), about your use of or interest in our services;

2.1.5. location information, including location information provided by
a mobile or other device interacting with one of our Websites, or
associated with your IP address, where we are permitted by law to process
this information;

2.1.6. activity, technical and device information about your use of our
Website, such as  the content you view, the time and duration of your
visit on our Website, how often you use  our services, how you first
heard about our Website, your preferences and
information about your
interaction with the content offered through our Website,your
model, device type, other unique device identifiers,operating system
version, browser type and IP address; and

2.1.7. social security numbers where we are required to do so for tax
or other legal reasons.



3.1. We collect information that Users provide to us in a variety of ways when Users visit our Website,  register on the Website purchase products on our Website, respond to a survey, fill out a form, and  in connection with other activities, services, features or resources we make available on our Website. You warrant any contact information you provide, included (but not limited to), your e-mail address  and mobile phone number is true and accurate. You further warrant that you are the telephone  subscriber and/or that you own any telephone numbers that you provide to Luckyland. You  acknowledge that by voluntarily providing your telephone numbers to Luckyland, you expressly agree  to be contacted at the telephone numbers you provide. You consent to receive pre-recorded voice  messages and/or autodialed calls (including text messages) by or on behalf of Luckyland relating to: 

1. this Privacy Policy and any associated terms and conditions.
2. any transaction with Luckyland related to your account; and
3. promotions from Luckyland.

3.2. The above communications may be made by or on behalf of Luckyland, even if your phone number is  registered on any state or federal Do Not Call list. You acknowledge that you may incur a charge for  these texts or calls by your telephone carrier and that Luckyland will not be responsible for these  charges. 

3.3. In addition to collecting information via our Website, we collect information from  Users by telephone, video or in correspondence (including email, live chat, mail, text message or social media). All telephone or video calls between Users and VGW Group representatives may be recorded for training, quality control and compliance purposes  and by continuing with any such call you consent to it being recorded. 

3.4. We also collect information about your use of our products and services through a  variety of technologies that are present when you visit our Websites or use our applications on third party sites or platforms (whether or not you are logged in or  registered) including cookies, flash cookies, pixels, tags and application program  interfaces (“API”). Please see the section entitled “Personal Data Collected via Technology” below for further information. 

3.5. Analytics tools are also used by us to collect information, including when you  visit our Website or use our applications or services on third party sites or platforms. 

3.6. Finally, we also use trusted sources to update or supplement the information you  provided or we collected, including in order to verify or validate information (for example, postal address, documentation and names).



4.1. The Data Controller is responsible for and may use your information for the purposes described in  this Privacy Policy. Other members of VGW Group may access your information where they act on  behalf of the Data Controller as a data processor for the purposes described in this Privacy Policy. In  summary, we use the information collected to operate our websites and to provide the services required by you, to facilitate your financial transactions, to respond to your questions and to fulfil all  the regulatory requirements such as anti-fraud checks and other checks required by the anti-money  laundering and other legislation. 

4.2. In accordance with applicable law and any elections made available to you, VGW may collect and use  the information of Users for the following specific purposes: 

4.2.1. To provide and manage the services you request - This includes,for
example,to process your registration, to set up and look after your account,
including checks made to guard against fraud.

4.2.2. To improve customer service and our services - Information you provide
helps us respond to your customer service requests more efficiently; we may
use feedback you provide to improve our products and services.

4.2.3. To process payments - We may use the information Users provide about
themselves when placing an order to service to that order (including to satisfy
our customers due diligence requirements and to establish the source of funds
where necessary). We do not share this information with third parties except
to the extent necessary to provide the service.

4.2.4. To personalize user experience - We may use information in the aggregate
to understand how our Users as a group use the services and resources provided
on our Website.

4.2.5. To contact you about our service - For example by email, live chat,
telephone, text message, mail, or social media; to manage promotions and
competitions you choose to enter. We may periodically contact you with offers
and information about the Services, including in connection with your accounts,
promotions, contests, online surveys, new features that you are entitled to
access, and other important information. As set out in clause 3.1, provision
of telephone information will be deemed as your consent to receive text
messages sent by automatic telephone dialing systems. Consent to receive
direct advertising is not a condition of purchase

4.2.6. To send important notices to you - From time to time, we may send
important notices to you, such as communications about purchases you have
made, or legal notices regarding the changes to our terms and conditions
or other policies. This information is important to your interactions with
us and you acknowledge that you may not opt-out of receiving these

4.2.7. To comply with our legal and regulatory obligations - We may use
information we collect about you to assess your social gameplay activity for
responsible social gameplay purposes, for taxation purposes, to comply with
fraud and anti-money laundering laws (including to establish the source of
funds where a transaction is involved) or to
comply with any other legal or
regulatory obligations (including the detection,
investigation and prevention
of activity that violates our terms and conditions or that may be illegal).

4.2.8. To offer alternative dispute resolution services. We may provide
information we collect about you to our third party partner for the specific
purpose of resolving any disputes that have not been satisfactorily resolved
through our internal processes.

4.3. We do not use automated decision making within the meaning of European data protection laws.



5.1. When you interact with our Website or any application accessible via our Website, we try to make  that experience simple and useful. We and our partners use industry standard identifiers, such as  cookies or other similar technologies. 

5.2. Our Website may use technologies to enhance User experience. These technologies are small files  that are placed on your computer, tablet, mobile phone or other devices when you visit a website.  They allow us to record certain pieces of information whenever you visit or interact with the  website. 

5.3. The following are examples of these type of technologies: 

5.3.1. Cookies. These are small text files placed in your device browsers
to store your preferences. Most browsers allow you to block and delete
cookies. However, if you do that, the service may not work properly. 

5.3.2. Pixel tags/web beacons. A pixel tag (also known as a web beacon) is
a piece of code embedded on the Scratch Carnival App that collects information
about Users' engagement on that web page. The use of a pixel allows us to
record, for example, that a user has visited a particular web page or clicked
on a particular advertisement. We may also include web beacons in e-mails to
understand whether messages have been opened, acted on or forwarded

5.3.3. Mobile device identifiers. We may share the advertising identifier
associated with your mobile device or tablet (such as the Apple IDFA and
Google Advertising ID) with advertisers. It is used to identify your device
for internet-based advertising. For instructions for using the advertising
choice mechanisms provided by the most popular mobile operating systems,
visit the NAI’s Mobile Choices page

5.3.4. Event tagging. Event tagging (including Facebook App Events and
Playfab Events) allows us to track actions that occur in the Scratch Carnival
App such as application installs and purchase events. By tracking these events
we can view analytics, measure ad performance, and build audiences for
ad targeting.

Behavioral Advertising 

5.4. We may partner with a third party to either display advertising on our Website or any application  accessible via our Website or to manage our advertising on other websites (for example, using  custom audiences on Facebook). Our third party partner may use technologies such as cookies to  gather information about your activities on our Website and other websites in order to provide you  advertising based on your browsing activities and interests. 

5.5. If you wish to opt-out of interest-based advertising, click here. Please note you will continue to receive generic advertisements.



General Rights 

6.1. We appreciate that by law and subject to certain conditions, you have a number of rights concerning  the personal information we hold about you. These rights include the right to access the personal  information we hold about you, the right to object to the processing of your data and the right to  withdraw any consent provided. In some circumstances, you can ask us to delete the personal  information we hold about you. 

6.2. To exercise the rights described in 6.1, please complete the Luckyland Customer Request Form here or alternatively email  

Right to complain to a supervisory authority

6.3. You also have the right to complain to the relevant data protection supervisory authority about our  processing of your personally identifiable information. 

Rights in direct advertising 

6.4. If we process your personally identifiable information for the purpose of direct advertising, you have  the right to object at any time to the processing of personally identifiable information relating to you  for the purpose of such advertising; this also applies to profiling, where appropriate, insofar as it is  associated with such direct advertising. 

6.5. You may opt-out of receiving commercial messages from us by following the instructions contained  in those messages or by contacting Customer Support. In the event of your objection to processing  for the purpose of direct advertising, we will no longer process your personally identifiable  information for these purposes.



7.1. We have in place physical, electronic and operational procedures to protect the personal information  that we collect. We adopt appropriate data collection, storage and processing practices and security  measures to protect against unauthorized access, alteration, disclosure or destruction of your  personal information, username, password, transaction information and data stored on our Website.  Our security measures are reviewed regularly and updated in keeping with technological advances.



8.1. We will retain your information for the period of time required to fulfill the purposes outlined in this  Privacy Policy unless a longer retention period is required or permitted by law.



9.1. We do not sell, trade, or rent the personal identification information of Users to others. However,  there are circumstances when we share your personal data with other companies in the VGW Group,  with third parties that provide services to you on our behalf, and with other third parties in the  course of complying with our legal obligations. 

With other companies within VGW Group 

9.2. We may share the information we collect with other companies in the VGW Group for the purposes  set out in this Privacy Policy. Please see Transfers below for further information on how we share  information within the VGW Group. 

With Third Parties 

9.3. We only share information with third parties in limited circumstances including the following:

9.3.1. when you allow us to share your information with third parties; 

9.3.2. when providing you with products and services and notifying you
about either important changes or developments to the features and operation
of those products and services;

9.3.3. with our service providers to enable us to provide our services, such
companies that help us with technology services, storing and combining
data, and processing payments and redemptions or providing relevant marketing,
including the delivery  of merchandise, and advertising for our products
and services.The partner companies will  have access to your personal
information only to perform services on our behalf and are
prohibited from
using your personal information for purposes other than those requested by
us or required by law. Where service providers use personal information for
their own  purposes, where permitted by law, such service provider will act
as data controller;

9.3.4. in response to lawful requests by public authorities, including to meet
national security or law enforcement requirements, when ordered to do so by
any regulatory body and/or under any legal provision contained in the governing
law of a particular

9.3.5. when instructing and authorizing the financial institution with which
a User’s account is held to disclose any information as may be requested by
a regulator in respect of the User’s account;

9.3.6. when we share your personal information with third parties to enforce
our terms and conditions set out on our Website, to protect our rights and
property and the rights and property of our customers and third parties,
to detect fraud or other
illegal activities and to comply with law or
legal processes; and

9.3.7. to perform customer due diligence including ID verification.

9.4. We make available an API provided by Google Maps in order to allow Users’ to have access to an  address auto-complete function on our Website.

The use of Google Maps for this purpose by the  User is subject to the then current Google Maps/Google Earth Additional Terms of Service at  and Google Privacy Policy  at

9.5. We may ask you to provide your image to assist us in verifying your identity. We do this by using  facial recognition technology provided by third parties (including, but not limited to, Jumio  Corporation) that determines whether the photo you take matches the photo in your identification  document. The facial recognition technology provided by these third parties collects information  from your image capture, including biometric data, and may share this information with us.  Biometric data is stored by the third party service provider in accordance with its privacy policy and is  stored by us, until such time as the initial purpose for collecting or obtaining such information has  been satisfied or within 3 years of your last interaction with us, whichever occurs first, provided we  have no other legal obligation to retain such information for any longer period. 

9.6. We may also share generic aggregated demographic information not linked to any personal  identification information regarding visitors and Users with our business partners, trusted affiliates  and advertisers for the purposes outlined above. 


9.7. VGW Group operates in several international jurisdictions and personal information we collect may  be transferred to, and stored and processed by, the European Union, the United States, Canada,  Australia, the Philippines or any other country in which we or our third party processors maintain  facilities. We will ensure that transfers of personal data to any country or organization are subject to  appropriate safeguards. Additionally, without limitation and where applicable, when transferring  personal information from the European Union, we may use standard contractual clauses approved  by the European Commission or otherwise in accordance with European data protection laws for  ensuring adequate safeguards.



Compliance with Children’s Online Privacy Protection Act

10.1. Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Website from those we actually know are under 18, and no part of our  website is structured to attract anyone under 18. 

Your California Privacy Rights 

10.2. California residents may learn more about their rights, including how to exercise their rights under  the California Consumer Privacy Act of 2018, by clicking here. 

Do-Not-Track Signals and Similar Mechanisms 

10.3. Some web browsers may transmit “do-not-track” signals to the websites with which the user  communicates. Because of differences in how web browsers incorporate and activate this feature, it  is not always clear whether users intend for these signals to be transmitted, or whether they even  are aware of them. Because there currently is no industry standard concerning what, if anything,  websites should do when they receive such signals, our Website currently do not take action in  response to these signals. If and when a final standard is established and accepted, we will reassess  how to respond to these signals.



11.1. This Privacy Policy may be updated from time to time to reflect changes in the way we work or the  way our work is regulated. We will notify you of material changes and, where required by law, will  obtain your consent. Notice may be by the posting of such changes on our Website or by other  means in accordance with applicable law. 

11.2. Any changes to the Privacy Policy will become effective when the updated policy is posted on our  Website. 

11.3. We encourage Users to frequently check this page for any changes to stay informed about how we  are helping to protect the personal information we collect.



12.1. Personal information means information that identifies (whether directly or indirectly) a particular  individual, such as the individual’s name, postal address, email address, and telephone number.  When anonymous information is directly or indirectly associated with personal information, the  resulting information is also treated as personal information. 

12.2. Anonymous information means information that does not directly or indirectly identify, and cannot  reasonably be used to identify, an individual. 

12.3. Aggregate information means information about groups or categories of customers, which does not  identify and cannot reasonably be used to identify an individual customer.



13.1. If you have specific questions regarding your personal information or how we use it, please contact  our Data Protection Officer directly by email at the following email address and  specify your place of residence and the nature of your question. Luckyland is located at 1209 Orange  St. Wilmington, DE 19801.

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